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In this case in which the petitioner-mother actively thwarted the respondent-father’s ability to have a relationship with their child, the evidence supports the trial court’s findings of fact, and the findings of fact support its conclusions of law that the father did not willfully fail to pay child support required by a court order, did

Even though the respondent-Father is not Native American, since his son’s mother is a member of the Monacan Indian Tribe, the Indian Child Welfare Act required DSS to undertake “active efforts” to prevent the breakup of the family. DSS’s creation of a case plan and communication of the plan to the incarcerated Father were insufficient